Privacy Policy

1. Information We Collect About You

Personal Information You Provide

We use the term "Personal Information" to mean any information that could be used to identify you, including your name, address, email address, birth date, financial information, cell or land-line phone number, or any combination of information that could be used to directly or indirectly identify you.

What Personal Information we collect from you depends on what Services you choose to use and how you interact with the Site:

Site Visitors

We have structured our Site so that, as a casual site visitor, you may come to our Site and review selected information about our Services without registering.

Investors

If you choose to access our Services as an Investor, we require that you complete a registration form. An Investor is an individual who is over the age of 18 and has completed the registration process on the Site. Our registration forms will specify the information which you must provide, which may include:

• Name
• Email address
• Phone number(s)
• Mailing address
• Social Security number (for IRS tax reporting purposes)
• Bank account information
• Birth date

We may require each Investor to provide information designed to verify his or her identity. This information may include: (i) information from a successfully completed electronic check transaction, (ii) a credit report, or (iii) other similar information designed to authenticate and confirm your identity or to otherwise comply with applicable law.

Location Data

We may collect your location information through our mobile apps by capturing the location (e.g., latitude/longitude) of your mobile device. If you have given the app permission to access your location, we may collect your device's location, even if you are not using the Service. If you want to opt-out of the collection of your location data, please adjust your settings in your mobile device.

Automatically-Collected Information

We, our service providers, and our marketing partners may automatically log information, such as the type of computer or mobile device accessing our Services, interactions over time with our Services, our communications (including emails and alerts), and other online services, such as:

• Device data: Operating system type and version, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, language settings, mobile device carrier, and general location information such as city, state, or geographic area.
• Online activity data: Pages or screens viewed, how long was spent on a page or screen, browsing history, navigation paths, access times, and duration of access, and whether marketing emails were opened or links within them clicked.

We and our third-party providers use the following tools for automatic data collection:

• Cookies: Text files that websites store on a visitor's device to uniquely identify the visitor's browser or to store information or settings in the browser.
• Local storage technologies: Like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data.
• Pixels/Web beacons: Tiny images that may be embedded within web pages and emails, used to learn more about your interactions with content.
• Other similar technologies: Including SDKs and mobile advertising IDs for similar purposes.

2. How We Use Personal Information

We use your Personal Information for the following business purposes:

• To process transactions that you have authorized us to make
• To facilitate your activities with respect to our Site
• To contact you regarding administrative issues, such as questions about your specific request, or otherwise respond to your comments or requests
• To verify and authenticate your identity, to help us ensure that the individuals who use the Site and Services are who they claim to be
• To prevent, detect, mitigate, and investigate fraud, security breaches, and potentially prohibited or illegal activities, including activities prohibited by the Anti-Money Laundering Act
• To help us operate our Site
• To deliver notices regarding your account
• To comply with IRS requirements and for tax reporting purposes
• To provide you with information, such as notices of investment opportunities via our Site or updates concerning investments that you have participated in
• To send you information we believe is relevant to you, such as news, bulletins, or other information
• To enforce this Privacy Policy and our Terms of Service
• To conduct user surveys and questionnaires
• To comply with applicable law

Marketing and Advertising

We and our advertising partners may collect and use Personal Information for marketing and advertising purposes, including:

• Direct marketing: We may from time to time send direct marketing communications including, but not limited to, communications about special promotions, offers, and events. Recipients may opt out of our marketing communications as described in the "Your Choices" section below.
• Interest-based advertising: We may engage third-party advertising companies and social media companies to display ads promoting our services across the web. These companies may use cookies and similar technologies to collect information and use that information to serve online ads that they think will be of interest.

We use aggregated information to analyze the effectiveness of our Site, to improve our Services, and for other similar purposes. We may disclose aggregated information to third parties, including advertisers.

3. How We Disclose Personal Information

We do not disclose your Personal Information to unaffiliated third parties except as provided in this Privacy Policy, as follows:

Service Providers

We may disclose Personal Information to third party companies and individuals that provide services on our behalf or help us operate our Services, such as hosting services, cloud services, information technology services, email communication software, payment processors, customer relationship management and customer support services, AI and chatbot services, and web analytics services.

Financial Accounts and Payments

For users who choose to link their bank accounts, we use service providers to facilitate the automatic connection with, and gather required transaction data from, your financial institution. In addition to facilitating transactions, we use these services to prevent overdrafts on your account and to prevent, detect, and mitigate fraud.

Advertising Partners

We may disclose Personal Information to third-party advertising companies for interest-based advertising purposes as described above.

Affiliates

We may disclose information to our affiliates, meaning an entity that controls, is controlled by, or is under common control with Fontavis. Our affiliates may use the Personal Information we disclose in a manner consistent with this Privacy Policy.

For Legal Reasons

We may disclose your Personal Information to the extent we reasonably believe we are required to do so by law or to comply with legal or regulatory requirements, or to protect against fraud, illegal activity, or to otherwise protect Fontavis against liability.

In Connection with a Corporate Transaction

In the event of a transaction or proposed transaction involving the transfer of substantially all of the assets of Fontavis or one or more of its businesses to another entity, whether an affiliate or a third party, or in connection with a bankruptcy, we may disclose your Personal Information in the diligence process or to otherwise facilitate the transaction.

For Safety & Security

We may reveal your Personal Information to third parties, including law enforcement agencies, in order to protect the safety and security of our employees and employees of our affiliates, users or of any third party.

4. Data Security

We have put in place safeguards to protect Personal Information against loss, theft, and unauthorized use, disclosure, or modification. With that said, there is no such thing as 100% security of the networks, servers, and databases we operate or that are operated on our behalf.

5. Data Retention

We keep your Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so in connection with your account, or as required by law (e.g., for tax, legal, accounting, or other purposes), whichever is longer.

6. Your Choices

If you choose not to provide certain Personal Information through our Site, we may not be able to provide certain services or process certain of your requests. You will not be able to become an Investor or use all of the features and products that we offer through this Site.

Depending on the functionality associated with the Site feature you are using, you may be able to update or delete certain of your Personal Information on the Site. However, please note:

• We may not be permitted to delete your Personal Information completely, due to IRS and regulatory reporting requirements, investments on the platform and the rights thereof, and data backups and records of deletions
• If you request deletion of your Personal Information, you may be unable to use certain features of the Site and any associated Services
• Certain of your Personal Information may remain in our databases following the deletion of your account
• We may not be able to remove de-identified, anonymous, or aggregate data from our databases

Any deletion requests may be sent to support@fontavisfinance.com.

Opt Out of Marketing Communications

If you no longer wish to receive marketing emails from us, you can opt out of these communications by clicking on the "unsubscribe" link included in those emails, or by contacting us at support@fontavisfinance.com. Please understand that you will not be allowed to opt out of transactional notices or other legal and related notices concerning your relationship to the Site or your account.

Online Tracking Opt-Out

There are a number of ways to opt out of having online activity and device data collected through our Services:

• Blocking browser cookies: Most browsers let users remove or reject cookies. To do this, follow the instructions in the browser settings.
• Blocking advertising ID use in mobile settings: Mobile device settings may provide functionality to limit use of the advertising ID associated with the mobile device.
• Using privacy plug-ins or browsers: You can use a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery, or uBlock Origin.

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, they will need to be separately configured on every browser and device that accesses the Services.

7. Children's Privacy

Our Site is not directed to children under the age of 18. We do not knowingly seek to collect or maintain Personal Information or other information from children under the age of 18. We will use commercially reasonable efforts to delete any Personal Information or other information later determined to be provided by a child under the age of 18. Use of the Site by children under the age of 18 is not permitted.

If you become aware that a minor has provided Personal Information through our Site, please email us at support@fontavisfinance.com.

8. Additional Notice to Certain State Residents

We are required by certain state comprehensive privacy laws, including the California Consumer Privacy Act of 2018 ("CCPA"), to provide this state notice to residents of certain states to explain how we collect, use, and disclose their Personal Information, and the rights and choices we offer such residents regarding our handling of their Personal Information.

Privacy Rights

State comprehensive privacy laws grant certain state residents the following rights:

• Information and Access: Certain state residents can request information about how we have collected, used, and shared their Personal Information during the past 12 months, and request a copy of the specific pieces of personal information we collect.
• Deletion: Certain state residents can ask us to delete the Personal Information that we collected or maintain about them.
• Correction: Certain state residents can request to correct inaccurate Personal Information that we maintain about them.
• Sensitive Personal Information: Certain state residents can request limitations on our use of their sensitive Personal Information in some circumstances.
• Opt out of Sale or Sharing: Like many businesses, we use services that display interest-based ads to users around the web. You may opt-out of this activity using the contact information below.

How to Submit a Request

Certain state residents may submit a request to exercise their rights by contacting us at support@fontavisfinance.com or at the mailing address in the "Contact Us" section of this Privacy Policy.

We will make an effort to fulfill verified requests within 45 days of receipt. However, the period for responding may be extended based on the complexity and the number of requests received. We will need to confirm the identity of the requester and their state residency in order to process requests.

How We Respond to "Do Not Track" Signals

Our Site currently does not respond to "Do Not Track" (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.

9. Changes to This Privacy Policy

We reserve the right to alter, modify, update, add to, subtract from, or otherwise change this Privacy Policy at any time, which will become effective as of posting on the Site. We encourage you to periodically review this Privacy Policy to stay informed about how we collect, use, and disclose Personal Information.

10. Contact Us

If you have any questions about this Privacy Policy, the practices of our Site or Services, or your dealings with our Site or Services, please contact us:

11. GLBA Privacy Notice (Appendix)

Rev. January 2026

WHAT DOES FONTAVIS FINANCE, LLC ("FONTAVIS") DO WITH YOUR PERSONAL INFORMATION?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

• Social Security number and income
• Investment experience and assets
• Account transactions and checking account information

When you are no longer our customer, we continue to share your information as described in this notice.

How?

All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons Fontavis chooses to share; and whether you can limit this sharing.

Questions?

Visit https://fontavisfinance.com

How does Fontavis protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does Fontavis collect my personal information?

We collect your personal information, for example, when you:

• Open an account
• Give us your contact information
• Provide account information
• Show your government-issued ID
• Buy securities from us
• Give us your income information
• Tell us about your investment or retirement portfolio

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can't I limit all sharing?

Federal law gives you the right to limit only:

• Sharing for affiliates' everyday business purposes — information about your creditworthiness
• Affiliates from using your information to market to you
• Sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.

Definitions

Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include companies with a Fontavis branded name.

Nonaffiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies. Fontavis does not share with nonaffiliates so they can market to you.

Joint marketing: A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Fontavis does not jointly market.